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New Jersey v. Dharun Ravi

State of New Jersey vs. Dharun Ravi was a criminal trial held in Middlesex County, New Jersey, Superior Court from February 24, 2012, to March 16, 2012, in which former Rutgers University undergraduate student Dharun Ravi was tried and convicted on 15 counts of crimes involving invasion of privacy, attempted invasion of privacy, bias intimidation, tampering with evidence, witness tampering, and hindering apprehension or prosecution.

Events leading up to the indictments and trial
First webcam incident Before September 17, 2010, Clementi had chatted online with a man whose identity has not been made public. While Ravi was out for the evening on September 17, the man came to Clementi's dorm room for the first time. On the nights of September 19 and 21, Clementi texted Ravi about using their room for the evening. On the first occasion, Ravi met Clementi's male friend, and Clementi said that the two wanted to be alone for the evening. In conversations with Wei and later text messages with friends, Ravi expressed distrust of the stranger that Clementi brought into the room, describing him as "an older, shabbier-looking guy". Ravi said he was worried about theft and that he left the computer in a state where he could view the webcam due to those concerns. However, other witnesses testified that Ravi said he also wanted to confirm that Clementi was gay. Ravi and Wei viewed the livestream via iChat for a few seconds, seeing Clementi and his guest kissing. Ravi posted to his 150 Twitter followers, "Roommate asked for the room till midnight. I went into molly's room and turned on my webcam. I saw him making out with a dude. Yay." Later, Wei turned on the camera for another view with four others in the room, though Ravi was not there. During this second viewing, Wei and others saw Clementi and his guest kissing with their shirts off and their pants on. Clementi viewed Ravi's Twitter posts 38 times following the first webcam viewing. Second planned webcam viewing On September 21, Ravi sent a friend a series of text messages, including messages saying, "Yeah, keep the gays away" and "People are having a viewing party with a bottle of Bacardi and beer in this kid's room for my roommate" along with directions on how to view it remotely. At 6:39 p.m., Ravi tweeted, "Anyone with iChat, I dare you to video chat me between the hours of 9:30 and 12. Yes, it's happening again." When Ravi's friend suggested that Clementi and his guest might use his bed, Ravi said "My webcam checks my bed, hahaha." When Clementi returned to his room, he noticed the camera and texted a friend saying he had unplugged Ravi's power strip to prevent further video streaming during his date. Ravi later said that he had changed his mind regarding the broadcast and disabled the camera himself by putting the computer to sleep. and two other officials that Ravi had used a webcam to livestream part of Clementi's private sexual encounter with another man. The resident assistant testified at trial that Clementi appeared shaky and uncomfortable when they met around 11 p.m., and in his official report of the meeting, the resident assistant said that Clementi requested both punishment and a room change for Ravi. In a formal e-mail request to the resident assistant made after the meeting, Clementi described the two viewing incidents, quoted from Ravi's Twitter postings, and wrote "I feel that my privacy has been violated and I am extremely uncomfortable sharing a room with someone who would act in this wildly inappropriate manner." and Yahoo! message boards about complaints he filed through university channels about his roommate. His posts indicated that he did not want to share a room with Ravi after he learned about the first incident and then discovered that Ravi invited his Twitter followers to watch a second sexual encounter. "He [the resident assistant] seemed to take it seriously," Clementi wrote in a post about 15 hours before his jump from the George Washington Bridge. On September 22, a friend of Ravi asked what had happened to the livestream the night before. Ravi responded, "It got messed up and didn't work." In the afternoon, the resident assistant confronted Ravi about Clementi's written complaint. Within a few hours, Clementi returned to his dorm room and he and Ravi were there together for less than an hour. ==Clementi's suicide and Ravi's apologies==
Clementi's suicide and Ravi's apologies
On the evening of September 22, the day after Ravi's second webcam transmission attempt, Clementi left the dorm room and got food. At around 6:30 p.m., he headed toward the George Washington Bridge. The prosecution noted that the apology came after Ravi learned he faced discipline by Rutgers. Prosecutor Julia McClure said that the apology was one of "many attempts" by Ravi to "dilute, cover up and explain, in other words to tamper with the facts and to fabricate evidence that could be looked on as favorable to him." Ten minutes later, Ravi texted again: ==Indictments==
Indictments
On September 28, 2010, Dharun Ravi and Molly Wei were charged with four and two counts of invasion of privacy, respectively, for their roles in the webcam spying incidents on September 19, 2010 and September 21, 2010. Under New Jersey law, one commits a fourth-degree crime of invasion of privacy if one observes another person without that person's consent under circumstances in which a "reasonable person would know that another may expose intimate parts or may engage in sexual penetration or sexual contact." A third-degree crime is committed if one discloses a "reproduction of the image" of the observed person. Ravi was charged with both third- and fourth-degree invasion of privacy. Soon after these charges were filed, there were calls from gay rights advocates and bloggers to include hate crimes charges against Ravi and Wei. Bruce Kaplan, the prosecutor in the case, said "now that two individuals have been charged with invasion of privacy, we will be making every effort to assess whether bias played a role in the incident, and, if so, we will bring appropriate charges." After further investigation, the prosecution concluded that there was evidence supporting a hate crime charge against Ravi, dating to when Ravi first learned of Clementi's name. The witness tampering charges were based on text messages Ravi sent to Wei, in which he tried to persuade her not to contradict what he had told police. In these messages, Ravi said "Did you tell them we did it on purpose?", and "Because I said we were just messing around with the camera." Wei responded "Omg dharun why didnt u talk to me first i told them everything". A key aspect of the prosecution's evidence tampering charge was Ravi's deletion of two potentially incriminating postings: one on Twitter on September 19 in which he wrote that his roommate was "making out with a dude. Yay", and one on September 21 in which he told his iChat followers "dare you to video chat me" during the time of Clementi's tryst. He replaced the latter post with one that said "don't you dare video chat me" at the time of the tryst, stating that the first message was a draft. and a former New Jersey federal prosecutor commented that, "there's no evidence of Ms. Wei doing anything. I'm very curious as to why the prosecutor is holding her responsible in any way, shape, or form simply because Mr. Ravi was using her computer." Pleas Wei and the prosecutor reached a plea agreement on May 6, 2011. Under the agreement, all charges against Wei would be dropped if Wei testified against Ravi and completed a three-year intervention program, including counseling and community service. Clementi's parents "supported leniency for Wei", believing that her "actions, although unlawful, were substantially different in their nature and their extent than the actions of Tyler's former roommate" and that she "was forthcoming and cooperative during the investigation." In December 2011, Ravi rejected a plea agreement in which he would not spend any time in jail and through which the prosecutor's office would assist him in fighting any potential deportation orders. Ravi is a citizen of India living legally in the United States. In rejecting the plea arrangement, Ravi's lawyer stated: "Simple answer, simple principle ... He's innocent. He's not guilty. That's why he rejected the plea." ==Trial arguments and testimony==
Trial arguments and testimony
Ravi was represented during the trial by attorneys Steven Altman and Philip Nettl of the New Jersey criminal defense law firm Benedict & Altman. The trial lasted 13 days with closing arguments ending on March 13, 2012. Pretrial motion In August 2011, Ravi's defense attorney requested a mistrial because the prosecution had not presented evidence to the grand jury which, he argued, would have cleared Ravi, and had presented other evidence in what he said was a misleading manner. This evidence included documents that showed that Clementi had titled files on his computer "Why does it have to be so painful" and took photographs of the George Washington Bridge a month before entering Rutgers. The judge did not grant Ravi's motion. Ravi was not charged with a role in the suicide. Opening arguments On February 24, 2012, Assistant Prosecutor Julia McClure told jurors that Dharun Ravi acted to "deprive" Tyler Clementi of his "privacy" and "dignity" when he observed an intimate encounter of Clementi and later invited others to watch a second liaison of Clementi and his friend. Ravi's actions were not, she emphasized, a "prank", "accident", or "mistake", but rather were "intentional", "planned", "criminal", and "mean-spirited". She said Ravi was motivated by the fact that Clementi was homosexual: "he sought to brand Tyler as different from everybody else" and "to set him up for contempt." Later, she explained, Ravi tried to "cover up the tracks" of his actions by altering evidence. Defense attorney Steven Altman said that Ravi's actions were those of an "18-year-old boy". He argued that although these actions may have been "immature" and "stupid", they were not hateful, bigoted, or criminal. "There was no bullying," Altman emphasized. Ravi never "harassed", "ridiculed", or even said "anything bad" about his roommate. Moreover, Altman said that Ravi saw only a few seconds of hugging and that nobody "transmitted" or "reproduced any image of anything". September 19 viewing: Testimony of Rutgers students Wei testified that, shortly after 9 p.m. on September 19, 2010, Dharun Ravi came to Wei's room and within a few minutes he showed her how he could get live images from his room via an auto-accept feature of his computer's video chat. Wei said that both she and Ravi were "shocked" when they saw Clementi and another man leaning against the bed kissing. Wei said that she and Ravi viewed for only a few seconds, turned off the livestream, and initially agreed not to tell anyone, because it "just felt weird" and she felt it was wrong. Several minutes later she chatted about the incident online. Wei said the scene was the same as that before, except that the men's shirts were off. According to one student, the two men were turned so one could not see their faces. Wei and other students testified that Ravi had told them that he was concerned about his possessions. Two of these students testified that Ravi also said he wanted to confirm that his roommate was gay. Several students described Clementi's guest as "shabby" or "shady". The prosecution argued that only Ravi and one other student had seen Clementi's guest in person and that the other student said the guest was not "anything out of the ordinary" and, while older, was "not obscenely old". None of the students said that Ravi had expressed any animosity towards gays. One student said that Ravi had called Clementi "nice", and another said that Ravi had told him he had a gay friend. M.B.'s testimony was important, not only because he himself was an alleged victim, but because the defense had portrayed him as a suspicious character that prompted Ravi's actions. According to former prosecutor John Fahy, it was also important for the prosecution to establish that sexual activity had occurred, and M.B. had to answer specific questions about the nature of that activity. Kate Zernike of The New York Times described M.B. as having "close-cropped hair", not dressed as casually as on September 19, 2010, but his "hair and bearing much the same" as in the Rutgers dormitory surveillance camera photo. She wrote that "he did not look, as Mr. Ravi's friends have described him, 'scruffy' or 'shady'." However, M.B. testified that he had not shaved the evening of the encounter. M.B. said that during the September 19 visit he noticed a webcam pointed at Clementi's bed and thought the position "was kind of strange", although he did not think that anyone was actually watching. In cross-examination, he noted he remembered this only when it later became relevant. M.B. also said that when he lay in Clementi's bed, he heard people joking and laughing in the courtyard, and it "seemed like the jokes were at somebody else's expense". When he left the room, there were about five students who "seemed to be looking at me and it seemed kind of unsettling". September 21: Timeline of Ravi's communications and events Ravi's communications, both in person and in texts and tweets, were key evidence in regard to the September 21 incident. The prosecution contended that on September 21 Ravi set up his webcam to view a second tryst of Clementi's and advertised it to friends and Twitter followers. The viewing was thwarted, they argued, only because Clementi unplugged the computer. Ravi said that his messages were made in a joking manner and that he later turned off the webcam so that no viewing would occur. Tyler Clementi followed Ravi's Twitter messages, visiting Ravi's Twitter page 38 times on the two days before his suicide. Clementi saved two of the messages. On September 20, Clementi saw the first message, which Ravi had made a few minutes after the September 19 viewing, and Clementi discussed it with friends. Ravi wrote: "Roommate asked for the room till midnight. I went into Molly's room and turned on my webcam. I saw him making out with a dude. Yay." The second saved message was sent by Ravi at 6:39 p.m. on September 21, after Clementi requested private use of the room for another tryst late that afternoon: "Anyone with i-chat, I dare you to video chat me between 9:30 and 12. Yes, it's happening again." On the afternoon of September 21, Ravi texted his friend Michelle Huang. Ravi said that Clementi's guest "was older and creepy and def from the internet". He said he had not seen the guest since September 19, but "My webcam checks my bed hahaha. I got so creeped out after Sunday." He then added, "Yeah keep the gays away." At 8:41, in another text conversation, Ravi told Huang that "people are having a viewing party" with rum and beer. Two Rutgers students testified that Ravi, in an apparent test of his webcam, used computers in their rooms to connect to his own. A Rutgers information technology analyst reported that iChat connections were made with Ravi's computer from these students' computers at 6:58 and 7:44 p.m. on September 21. The second student said that after dinner Ravi "hyped up" his earlier "dare you" tweet, that Ravi used her computer to access his iChat, and that "Tyler's side of the room came into view" when the webcam was accessed. The first student said that the next day he told Ravi that the livestream had not worked: "Then I saw [Ravi] in the lounge and I said, 'Yo, it didn't work.' And he said, 'Yeah, I have been getting that from a lot of people. At 9:15 p.m., Clementi saved a screenshot of Ravi's "dare you to video chat me" tweet. At 9:25, Ravi's computer was disconnected, according to analysis by the Rutgers IT expert, and it stayed disconnected till 11:19 p.m. Shortly after 11 p.m., Ravi texted Clementi to see if he was still using the room. At 11:48, Clementi texted Ravi that "we're done." Clementi's complaints to Rutgers officials Only a portion of Clementi's requests for a room change were permitted to be seen by the jury. After discussing with friends Ravi's first Twitter message ("saw my roommate making out with a dude"), Clementi, at 3:55 a.m. on September 21, filed a request on the Rutgers housing website; he wrote, "roommate used webcam to spy on me/want a single room." The part about spying was ruled hearsay and not admissible. Late on the evening of September 21, after seeing Ravi's "dare you" tweet and just before his meeting with M.B., Clementi visited a resident assistant, Rahi Grover. Grover was not permitted to testify about what Clementi said, but did testify about Clementi's demeanor. He said that Clementi's voice was "a little shaky" and that he appeared uncomfortable. The judge allowed some parts of Grover's official report of the incident: "Tyler is quite upset and feels uncomfortable. Tyler prefers some sort of roommate switch ASAP and prefers some sort of punishment for Dharun Ravi." Grover also included his own recommendation that a roommate change be made as soon as possible, and he offered Clementi a bed in his own room for that night, which Clementi declined. According to former prosecutor John Fahy, Clementi's e-mail and Grover's testimony were important in regard to whether or not Clementi "reasonably believed he was being intimidated". Reactions to prosecution Observers who commented after the prosecution rested its case, and before the defense brought its arguments, differed on the strength of the prosecution's case. Susan Abraham, a law professor and former public defender, said that she believed that the prosecution had established both the invasion of privacy and the bias intimidation charges. There is "no question", she said, that Clementi believed he was selected because of his sexual orientation, and some of Ravi's messages referring to gays might also be evidence of intent; she noted that, under the New Jersey bias intimidation law, the prosecution does not have to prove a biased intent, but only a reasonable belief by the victim that he was targeted because of sexual orientation. Abraham also guessed that one defense argument would be that, when Ravi admitted to violating privacy in his statements to the police, he did not understand the legal meaning of "invasion of privacy" and made the statement under duress. After the indictments, attorney Edward Weinstein had said that the prosecution case might be weak, but after hearing the prosecution case, he concluded that "The defense has an extremely large burden; the prosecution put on a good case." He noted that Ravi's Twitter messages, revealed during the trial, showed that "he was not just a mischievous kid pulling a prank", though he also felt that the outcome of the case "totally remains to be seen". Jack Levin, an authority on hate crimes, was skeptical of the case for bias intimidation, saying of Ravi that "it becomes difficult to determine whether the motivation was due to sexual orientation or some other conflicts between the roommates that have nothing to do with sexual orientation", although he also noted that the position of the camera had raised doubts about Ravi's contention that he was primarily concerned about protecting his possessions. John Fahy, a former Bergen County Prosecutor, said after closing arguments that both the defense and prosecution did a "very good job". In regard to the invasion of privacy charge, Fahy said the defense was effective in raising reasonable doubt by characterizing the incidents as a "frolic" of "first-year college students". Regarding bias intimidation, Fahy said that there was "not a lot of proof" that the viewing was done because Clementi was gay. In regard to obstruction of justice, Fahy noted that a few texts by Ravi were "very difficult to explain". Fahy said that the police interview revealed a "kid not used to being interrogated" and that the interview contained "one big lie" by Ravi—that in the second (September 21) incident he had "turned the computer off and later turned it on." == Verdict ==
Verdict
Jury decision After 12 hours of deliberations over two and a half days, a jury of 12 members and three alternates reached a verdict on March 16, 2012. Ravi was found guilty of invasion of privacy, hindering apprehension, witness tampering, and all four of the bias intimidation counts. In regard to the viewing on September 19, the jury concluded that Ravi did not act with the purpose to intimidate either Clementi or his guest because of their sexual orientation, but that Clementi was intimidated and reasonably believed that he had been targeted because of his sexual orientation. Clementi's guest, identified only as MB at the trial, reacted to the verdict on March 16, 2012. He said, "I had hoped for all concerned that a trial could have been avoided, but that was not my choice. It was Mr. Ravi's decision, and now he will have to live with it." MB's attorney said that the jury had been thorough and that the jury was correct in not finding MB to be the victim of a bias crime since the Rutgers students "didn't know anything about our client". The trial and the verdict sparked nationwide debate on the validity and efficacy of the New Jersey hate crime statute and similar laws. Glenn Berman, the judge who presided over Ravi's trial, said that the New Jersey statute was "muddled" and that he would have written it differently. The editorial board of the Newark newspaper, The Star-Ledger, criticized both the law and its application, arguing that Ravi's crime was not malicious, the law was unconstitutional, and the application of the law against Ravi was a "huge overreach". Washington Post columnist Richard Cohen criticized Ravi for "bullying (via webcam)", but argued that hate crime laws unfairly punish an individual for thought or speech, and therefore erode civil liberties. In a New York Times op-ed piece, journalist Emily Bazelon argued that, while Ravi's invasion of Clementi's privacy "should be out of bounds on a college campus," the punishment he faced was disproportionate to that crime, and that hate crime laws were not intended for these types of actions. == Sentencing hearing ==
Sentencing hearing
Sentence On May 21, 2012, Judge Glenn Berman sentenced Ravi to 30 days in jail, 3 years' probation, 300 hours of community service, a $10,000 fine, and counseling on cyberbullying and alternate lifestyles. Lead prosecutor Julia McClure had sought a five-year prison term and on May 23, 2012 filed a motion appealing the sentence. On May 30, 2012, Ravi waived his right to remain free during the appeals process and began his jail term at the Middlesex County Adult Corrections Center in North Brunswick, New Jersey on May 31, 2012. Ravi was released from jail on June 19, 2012, after serving 20 days of his 30-day term, with 5 days of credit for good behavior and 5 days of work credits. Ravi is a permanent resident of the United States who immigrated at age 6. Clementi's family, M.B., and the judge all recommended Ravi not be deported. In June 2012, Immigration and Customs Enforcement officials announced that the convictions were not serious enough to seek deportation. Apology issue Judge Berman said that Ravi's "'letter of apology' to the pre-sentence people" was "unimpressive" and "didn't even mention the seven cover-up charges". He said it was "ironic" that Ravi's letter "doesn't mention M.B. as if he doesn't exist", yet M.B. had in his letter offered to write a letter to help Ravi avoid deportation. Ravi declined the opportunity to speak at the sentencing hearing and was reprimanded by Judge Berman for not having publicly apologized: "I heard this jury say guilty 288 times—24 questions, 12 jurors, that's the multiplication. And I haven't heard you apologize once." On May 29, 2012, Ravi released the following statement: Clementi's parents responded: ==Appeals ==
Appeals
Both the prosecutors and Ravi filed separate appeals. In February 2016, Ravi asked the courts to overturn his convictions. On September 9, 2016, the Superior Court of New Jersey, Appellate Division overturned the conviction after the New Jersey Supreme Court ruled that the bias intimidation laws under which Ravi had been convicted were unconstitutional. The appeals court ordered that Ravi could be re-tried on ten other charges. Ravi accepted a plea deal on October 27, 2016, and pleaded guilty to one count of attempted invasion of privacy, a third-degree felony. He was sentenced to time already served and fines paid, and the remaining charges against him were dropped. ==References==
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